We manage energy project development, environmental permitting, remediation and compliance, insustrial hygiene, health & safety, auditing, environmental management, government relations. We solve your problems in all of these areas. We move quickly and dig deeply to reach your goals. We work wherever you are.
How can SMG help you?
SMG POV
EPA and Army Corps of Engineers Clarify Protection for Nation’s Streams and Wetlands in New Proposed Rule
WRITTEN BY
Karen Thompson, P.G.TAGGED
We told you last week that the USACE and EPA had issued a proposed rule defining key provisions of the Clean Water Act. Click here for that blog entry. The most substantial change in the new rule is the proposed deletion of the existing regulatory provision that defines “waters of the “United States”. Waters in a watershed in which there is no connection to a traditional navigable water, interstate water or the territorial seas would not be “waters of the United States.” Under the proposed rule, other waters (not traditional jurisdictional waters) would only be jurisdictional upon a case-specific determination that they have a significant nexus as defined by the proposed rule.
FEATURED PROJECT
PROBLEM
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG'S APPROACH
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
MG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
RESULTS
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.